Anti-corruption AND BRIBERY policy

Martin Bencher Group adheres to a zero-tolerance policy on corruption.

The legal definition varies by legal jurisdiction, so Martin Bencher Group has adopted the following definitions in order to be clear with what it means in our organization.

Martin Bencher Group bribery definition:

The offering, giving, soliciting, or acceptance of an inducement or reward which may influence any person to act morally or legally inappropriate.

Martin Bencher Group anti-corruption definition:

the abuse of entrusted power for private gain. This definition captures three elements of corruption. One, corruption occurs in both the public and private sectors (and media and civil society actors are not exempt). Two, it involves abusing power held in a state institution or a private organization. Three, the bribe-taker (or a third party or, for example, an organization such as a political party) as well as the bribe-giver benefit, whether it be in terms of money or an undue advantage.

At Martin Bencher we will not tolerate any form of corruption or bribery.

All Employees are encouraged and obliged to raise concerns at the earliest possible stage about any indications of bribery and / or corruption. To report issues or concerns, please contact the CEO of Martin Bencher Group.

Any employee of Martin Bencher Group involved in corruption or bribery activities will be subject to sanctions and penalties aligned to the gravity of the offence. The strictest disciplinary measures will include termination of employment and reporting to the authorities for criminal investigation.

Martin Bencher´s Anti-Corruption / Bribery Policy is valid for all the Martin Bencher offices worldwide and will be regularly monitored to ensure that the objectives are achieved. It will be reviewed and, if necessary, revised in the light of legislative or organizational changes.